The Federal Court of Appeal’s (“FCA”) decision in Enns v. Canada[1] clarifies how “spouse” is defined for purposes of paragraph 160(1)(a) of the Income Tax Act (“ITA”). This decision carries significa...
When CRA issues a Notice of Reassessment (NoR), taxpayers who contest it face a structural choice: remain in CRA’s self-adjudication stage at objection, or transition to the Tax Court’s independent ov...
This article was prepared by Counter LLP’s Tax Controversy and Litigation practice, with contributions from Peter Aprile, Senior Counsel; James Roberts, Partner; and Jennifer Mak, Associate. The CRA o...
Counter Tax Litigators LLP has contributed an updated chapter on Income Tax Penalties in Canada, authored by Peter Aprile, James Roberts, and Jennifer Mak, and published by Thomson Reuters in its Tax ...
Coopers Park (2024 TCC 122) shows CRA intensifying its push to access accountant communications in tax disputes. The risk rises when legal and accounting teams blend, and it remains invisible until th...
The Federal Court of Canada’s decision in Onex Corporation v. Canada (Attorney General)[1] highlights a meaningful development for taxpayers challenging the Agency’s discretionary decisions. The FC’s ...
Counter Tax Litigators LLP proudly announces the International Tax Review has named Peter Aprile, Senior Counsel and Practice Group Leader, a finalist for the Tax Disputes & Litigation Practice Leader...
Counter Tax Litigators LLP proudly announces its recognition by the International Tax Review (ITR) in the prestigious ITR World Tax 2025 Rankings for its expertise in Tax Controversy (Canada).
Counter Tax Litigators LLP proudly announces that it has been shortlisted for the prestigious Tax Innovator of the Year award by International Tax Review. This esteemed recognition celebrates the firm...
Recent Supreme Court of Canada (SCC) rulings provide critical guidance on tax dispute jurisdiction, shaping how tax reassessments and ministerial decisions should be challenged.